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Privacy Policy & POPIA Framework

How AcademyPro and CodeWays PTY LTD collect, safeguard, process, and retain student-athlete and coaching records in strict compliance with the Protection of Personal Information Act (Act 4 of 2013).

Effective: August 17, 2026
Version 3.2
POPIA Act No. 4 of 2013 Verified

Minor Athlete Warranties

Strict Section 34/35 POPIA compliance with mandatory school parental consent warranties for athletes under 18.

Zero Data Monetization

We never sell, rent, or commercialize player performance or contact records to commercial advertisers or scouts.

Athletic Disclaimer

Performance benchmarking software, not a medical device. Training clearance remains the school staff's responsibility.

24h Auto-Purge Protocol

Automated database cleanup permanently purges completed action plans older than 24 hours for data minimization.

1

Scope, Identity & Legal Framework

This Privacy Policy governs the processing, security, and lifecycle management of personal information collected through the AcademyPro Performance Platform, comprising the Coach Mobile Application (iOS & Android), the Web Administration Portal (admin.academypro.co.za), backend API services, and the official website (academypro.co.za).

AcademyPro is operated in South Africa by CodeWays PTY LTD ("AcademyPro", "we", "us", or "our"). This policy is drafted in strict accordance with the Protection of Personal Information Act, Act No. 4 of 2013 (POPIA), the Promotion of Access to Information Act, Act No. 2 of 2000 (PAIA), the Children's Online Privacy Protection Act (COPPA), and international student privacy best practices.

Scope of this Policy

This policy applies to all subscribing high schools, sports clubs, athletic directors, rugby coaches, medical and physiotherapy staff, student-athletes, and parents or legal guardians accessing AcademyPro platforms.

2

Institutional Roles: Responsible Party vs. Operator

Under South African law (POPIA Section 1) and global data protection regimes, legal accountability is bifurcated as follows:

Subscribing School / Club

Acts as the Responsible Party (Data Controller). The school determines legitimate athletic development purposes, manages student-athlete enrollments, and guarantees legal authorization.

AcademyPro / CodeWays

Acts strictly as an Operator (Data Processor). We process and store athletic records exclusively pursuant to the school's authorized instructions and institutional SaaS agreement.

3

Minor Student-Athletes & Parental Consent Warranty

Mandatory Institutional Warranty (POPIA Section 35)

By registering student-athletes under 18 years of age on AcademyPro, the subscribing school or sports club expressly warrants and represents that it has secured verifiable written parental or legal guardian consent for the collection, logging, and processing of the child's personal, athletic, and physical conditioning information.

In accordance with Section 35(1) of POPIA, the prohibition on processing personal information concerning children does not apply where processing is carried out with the prior consent of a competent person (parent/legal guardian) or is necessary for the establishment, exercise, or defense of a right or obligation in law.

4

Categories of Data Collected & Processed

Under POPIA Condition 2 (Processing Limitation), we collect and process only the minimal data strictly necessary for athletic roster organization, performance auditing, training session coordination, and player safety:

A. Student-Athlete Roster Profiles

Full legal name, preferred playing name, date of birth, age tier (U14, U15, U16, First XV), school grade, jersey number, playing positions (primary & secondary), profile photo, and institutional student identifier.

B. Parent Emergency Contacts

Parent/guardian name, verified primary mobile number (for emergency athletic notifications and SMS alerts), email address, and designated emergency contact status.

C. Coaching Staff Credentials

Coach full name, official school email, sport specialization (Head Coach, S&C Coach, Physiotherapist, Director of Sport), cryptographic password hash, and granular role permissions.

D. Session Attendance & QR Records

Training session timestamps, fixture participation records, QR code verification scans, and absence classifications.

5

Athletic Baseline Testing & Physical Benchmarks

AcademyPro allows strength and conditioning specialists to log athletic performance variables to monitor physiological progression:

Sprint & Speed Metrics

10m split, 20m acceleration, and 40m top-end sprint timings.

1RM Strength Benchmarks

Back squat, bench press, trap bar deadlift, and power clean.

Aerobic & Anaerobic Tests

1.2km Bronco shuttle test and Yo-Yo Intermittent Recovery splits.

Anthropometrics & Reach

Height (cm), body mass (kg), standing reach, and vertical jump.

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Special Personal Information: Health & Injuries

Under Section 26 and Section 32 of POPIA, information concerning an individual's physical health or medical history constitutes Special Personal Information.

AcademyPro processes health status, active injury markers, physical readiness indicators, and medical clearance notes solely where authorized by the school's medical/physiotherapy staff for the direct purpose of protecting the athlete's physical well-being, preventing reinjury during high-impact rugby training, and coordinating graduated return-to-play protocols. Access is strictly restricted via Role-Based Access Control (RBAC).

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Athletic Platform & Medical Liability Disclaimer

Limitation of Health & Athletic Liability

(a) Not a Medical Device: AcademyPro is an athletic record-keeping and team communication tool. It is NOT a medical device, diagnostic system, or licensed healthcare provider. Baseline metrics, Bronco scores, and 1RM tracking algorithms are informational benchmarks and do not substitute for qualified medical judgment.

(b) School Supervision: The subscribing school, sports directors, and accredited coaching staff maintain sole responsibility for ensuring athletes are medically cleared to perform physical conditioning tests and participate in contact rugby fixtures.

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Lawful Grounds for Processing (POPIA Section 11)

Under Section 11 of POPIA, personal information may only be processed if a specific lawful basis applies:

1 Performance of a Contract

Fulfilling our SaaS licensing agreement with the subscribing high school or athletic organization.

2 Explicit Consent

Verifiable written consent provided by parents/guardians during school enrollment or team registration.

3 Legitimate Interests

Fostering student athletic progression, injury prevention, and institutional sports management.

4 Vital Interests

Emergency field-side scenarios where designated parents or paramedics must be notified immediately.

9

Automated Purging & Data Retention Standards

To minimize data retention in accordance with Section 14 of POPIA, AcademyPro implements rigorous lifecycle standards:

Automated 24-Hour Action Plan Purge Protocol

When an individual athlete Action Plan is marked as complete (is_completed = 1), the system automatically timestamps completion and permanently purges the record after 24 hours (86,400 seconds) to ensure temporary notes are not stored unnecessarily.

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Zero Selling of Data & Authorized Operators

We do NOT sell, rent, monetize, or disclose student or coach personal information to third-party commercial advertisers or data brokers under any circumstance.

Operator Category Operational Purpose Security Safeguards
Cloud Infrastructure (Cloudflare) D1 database hosting, automated backups, TLS 1.3 edge security ISO 27001, SOC 2 Type II, AES-256 at rest
Transactional SMS Gateway Dispatching emergency fixture alerts to parent mobile phones Encrypted API transmission, zero marketing use
Transactional Email Service Delivering coach onboarding invitations and password recovery DKIM/SPF authenticated, TLS in transit
11

Technical & Cryptographic Security Safeguards

AcademyPro incorporates defense-in-depth technical and organizational measures to safeguard records:

TLS 1.3 & AES-256 Encryption

All mobile app and web portal traffic is strictly enforced over TLS 1.3 encryption. At-rest databases are AES-256 encrypted.

Prepared SQL Parameterization

100% prepared SQL statements with parameterized variable bindings (.bind()) across all endpoints.

Role-Based Access Control (RBAC)

Granular permission isolation between athletic directors, rugby coaches, medical staff, and age-group managers.

Masked Logs & Cryptographic JWT

Cryptographically signed JSON Web Tokens with strict session expirations. Zero plaintext credential logging.

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Institutional Offboarding & Permanent Deletion

Upon termination of an institution's subscription or upon receipt of an authorized deletion request from a school's athletic director:

  • The school is provided with a 30-day export window to download all squad test baselines, sprint splits, and attendance audits.
  • Following the export window, all identifying student records, emergency phone numbers, and profile photos are permanently purged from live production databases.
Need to request deletion of your AcademyPro mobile app account or athletic data? Account Deletion Portal
13

Your Data Subject Rights Under POPIA

Parents, legal guardians, and coaching staff retain statutory rights under Chapter 3 of POPIA:

A Right of Access (Section 23)

Request confirmation of whether we hold personal information and request a copy of such record.

B Right to Correction (Section 24)

Request the correction, completion, or updating of inaccurate or outdated athlete data.

C Right to Object (Section 11(3))

Object on reasonable grounds to the processing of personal information where processing is based on legitimate interest.

D Right to Complain

Lodge a complaint with the South African Information Regulator if you believe your privacy rights have been infringed.

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Information Officer & Regulatory Contacts

AcademyPro (CodeWays PTY LTD) — Compliance Office
Attention: Information Officer
Compliance Email: privacy@academypro.co.za
Country / Region: South Africa
Response SLA: Within 30 Calendar Days
The Information Regulator (South Africa)

If you are dissatisfied with our response to your inquiry, you have the right to lodge a formal complaint with the South African Information Regulator:

Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
General Enquiries: enquiries@inforegulator.org.za
Official Website: https://inforegulator.org.za

Frequently Asked Questions

Everything athletic directors, head coaches, and parents need to know about school compliance and student data protection.

Schools can export individualized athletic baseline reports (such as Bronco progression, sprint splits, and 1RM gains) to share directly with parents during term reviews or parent-coach conferences.
Only authorized coaching staff provisioned by the school's sports director can access specific squads. Staff accounts are protected with role-based permissions and secure token authentication.
Graduating athlete profiles are archived according to the school's record retention schedule. Identifying contact numbers can be purged upon request while maintaining historical squad statistics.
Never. AcademyPro enforces a strict zero-commercialization guarantee. Athlete data belongs exclusively to the subscribing school and student-athlete.
AcademyPro strictly adheres to Sections 34 and 35 of the Protection of Personal Information Act (POPIA). We mandate that subscribing schools obtain written parental/guardian consent prior to roster registration, implement role-based access control, and enforce automated purging protocols for temporary action plans.
POPIA & DPA Governance

Have Questions About School Compliance?

Our compliance and technical team is available to assist high school governing bodies, headmasters, and sports directors with custom Data Processing Agreements.